• Because the transfer is incomplete, some or all of the property’s value will be included in the transferor’s gross estate. IRC (26 USCA) §§ 2036–2038. [Cases: Internal Revenue 4159(3). C.J.S. Internal Revenue § 515.]
incomplete transfer
Tax. A decedent’s inter vivos transfer that is not completed for federal estate-tax purposes because the decedent retains significant powers over the property’s possession or enjoyment.